TechDocs/DataProcessingTransparency

FSFE Records of processing activities

The goal of this page is to provide information regarding data processing at FSFE. It is still a work in progress and we are constantly improving the information. In case you have any questions about it, please get in contact with privacy@fsfe.org.

The FSFE e.V., Schönhauser Allee 6/7 Stairway 2, 5. floor 10119 Berlin Germany, is controller for all those processings, the most effective ways to contact the association are on our contact page.

Web sites : visitors

Service

Processing

What data is processed?

Why is the data processed?

What legal authorization do we have according to Article 6 of GDPR?

Who has access?

What is our Data retention policy?

FSFE website

Users visiting the website

??

The web server needs the public IP addresses to serve the pages, we also use those data for debugging and security purposes

Legitimate Interest

PMPC website

Users visiting the website

Source IP, Date, HTTP request, User-agent.
The source IP is the IP address of our reverse proxy, not a personnal information

The web server needs the public IP addresses to serve the pages, we also use those data for debugging and security purposes

Legitimate Interest

Sysadmin

The campaign's duration (to be confirmed 1)

PMPC website

Signing the open letter

Email and name, country, ZIP code, comment
Italic information is voluntary

To display signature of the open letter;
to give updates about the campaign(specific consent)
To add the signature to the public list(specific consent)

Consent
Link to privacy policy

The public list is accessible to everyone
PMPC coordinator and Sysadmin for others information

The campaign's duration

art13 savecodeshare.eu

Signing the open letter

Name, email, country
Italic information is voluntary

To display signature of the open letter;
to give updates about the campaign (specific consent)

Consent
Link to privacy policy

Signatures will be handed over to the Members of the European Parliament and the EU Council
Sysadmin access everything

Data is stored for the container lifetime (i.e. the campaign's duration)
Data may be kept by the Members of the European Parliament and the EU Council for an unknown time

art13 savecodeshare.eu

Visiting the website

IP addresses, SQL statements for error messages contain personal information
The IP is the IP address of our reverse proxy, not a personnal information

The web server needs the public IP addresses to serve the pages, we also use those data for debugging and security purposes

Legitimate interest

system administrators

Data is stored for the container lifetime (? 2)

Blogs

User visiting the website

IP addresses

The web server needs the public IP addresses to serve the pages, we also use those data for debugging and security purposes

Legitimate Interest

(missing information 3)

(missing information 3)

Wiki

User visiting the website

Source IP addresses

The web server needs the public IP addresses to serve the pages, we also use those data for debugging and security purposes

Legitimate Interest

Wikicare takers, system-hackers

We store data for 14 days

Social Media

If you do not click on any external buttons to external sides, data will not be transferred. [TODO : Add references to privacy policies of the services we use.]

Collaboration

Service

Processing

What data is processed?

Why is the data processed?

What legal authorization do we have according to Article 6 of GDPR?

Who has access?

What is our Data retention policy?

Community Database and LDAP server

FSFE account management

Name, email address, username, password hash

Managing access to FSFE's online services

Legitimate interest

Community database administrator

Data is stored as long as the account exists

Community data maintenance

Birthday, sex, preferred language, postal address, secondary email address

Managing FSFE's community of contributors

Consent

Community database administrator

Data can be changed or deleted at any time by the subject

Wiki

FSFE Wiki

Account data (Name or Username, Pseudonym, email address from the FSFE account, optionally jabber ID), a dedicated personal page (optional), attribution for all contributions

Wiki management and attribution of work

Contract

Public pages are accessible to everyone, other pages may have limited access depending on ACL

As long as the account exist (to be confirmed 1)
As the account is the base to attribution of contribution, we do not delete account without the data subject request.

Gitea

FSFE Gitea contributions

Emails and usernames of registered users and the files they work with; webserver logs (source IPs)

For authentication and operation of the platform; attribution of contribution; webserver logs for debugging

Contract

contribution are public, logs are accessible only to Service maintainers, system administrators

As long as the account exist (to be confirmed 1)
As the account is the base to attribution of contribution, we do not delete account without the data subject request.

1 week for logs

FSFE website

Translators of the website

name or pseudonym of translators of each page

To attribute translation to its translators whenever they accept to be cited

Consent

public information

Attribution is kept as long as the translation exist

Reimbursements

Financial reimbursements for expenses

All communication around the reimbursement including payment data

Reimbursing (paid and volunteer) contributors for their expenses

Contract

Financial team, parties involved in the payment processing, tax consultant, public authorities

Data is stored according to statutory storage periods

Orders

Processing

What data is processed?

Why is the data processed?

What legal authorization do we have according to Article 6 of GDPR?

Who has access?

What is our Data retention policy?

Promotion material orders

Order information from this form

Answering of incoming requests, sending packages, and requesting feedback

Contract

FSFE office staff and financial team

Data is stored for 13 months after the order

Generating statistics about promotion material orders

Legitimate interest

Payment information in case a donation is made along with the order

Accounting

Legal requirements

Financial team, parties involved in the payment processing, tax consultant, public authorities

Data is stored according to statutory storage periods

Merchandise orders

Order information from this form

Answering of incoming requests, and sending packages

Contract

FSFE office staff and financial team.

Data is stored for 13 months after the order

Payment information

Accounting

Legal requirements

Financial team, parties involved in the payment processing, tax consultant, public authorities

Data is stored according to statutory storage periods

Donations

Processing

What data is processed?

Why is the data processed?

What legal authorization do we have according to Article 6 of GDPR?

Who has access?

What is our Data retention policy?

All Donations

Name, email address, date of payment, payment method, amount

Processing the donation, accounting

Legal requirements

Community database administrator, financial team, parties involved in the payment processing, tax consultant, public authorities

Data is stored according to statutory storage periods

Supporter contributions

Name, email address, date/method/amount of last payment, automatic renewal status

Reminding supporters of the next contribution

Contract

Community database administrator

Data is processed as long as the subject participates in FSFE's supporter program

Donations for which a donation receipt is requested

Name, postal address, date of payment, amount, date of donation receipt

Issuing donation receipts

Legal requirements

Community database administrator, financial team, tax consultant, public authorities

Data is stored according to statutory storage periods

Donations >= 480 € per year or 40 € per month

Name, donation category

Maintaining the public donors list for reasons of transparency and recognition

Consent

This data is public

As long as the FSFE exists or until the person revoke his or her consent

Communications means

Service

Processing

What data is processed?

Why is the data processed?

What legal authorization do we have according to Article 6 of GDPR?

Who has access?

What is our Data retention policy?

Community emails

Emails from the FSFE to its communiy

Name, email address, preferred language (optional), sex (optional, to allow for correct grammar), postal address (optional, to allow for region-specific information)

Keeping the FSFE community informed

Consent

Community database administrator

Consent can at any time be revoked by the subject

Mailman

Mailing lists (https://lists.fsfe.org/mailman/listinfo)

Email address, full name or pseudonym (if the person choose to insert one), subscription details, logging see the official Mailman page

To manage the mails going from and to the list the individual subscribed to.

Consent (for each mailing list)

Mails on the mailing list may have different level of publicity from public (archive included) to restricted to a given group (see description of the list for more information) <BR> ADMIN-TECH,List-Admins,team@ may have access to all mails

Posts and subscriptions are stored for 1 year, bounces and errors are stored for 1 month, messages sent by Mailman itself are stored for 1 week, digests are stored for 4 months

QuickML

Mailing list

Email addresses

To manage the mails going from and to the list the individual subscribed to.

Consent (for each mailing list)

??

??

Newsletter

Newsletter

Email addresses, preferred language

To send the newsletter in the good language

Consent

Sysadmin, PR team

As long as subscribed.

OTRS

Tickets processing

All communication around the tickets, in the format of emails exchanged

Answering of incoming requests.

Consent

FSFE core team.

The time to close the issue raised + X months (To Be determined 1)

Discourse

Webserver

IP Addresses, post timings, usernames, posts

IP addresses are collected by discourse to prevent and block spam

Consent

system administrators + service maintainers

Data is stored for the container lifetime

CARE Team

CoC and sanction management (To be confirmed 2)

Depending on the situation, identification data (name/pseudo/description), contact (emails, phone number) etc.

Data are processed to solve CoC infringement
It may imply to enforce sanction like banishment of mailing-list or events

Legitimate interest

CARE Team

The time needed to solve the situation. Information regarding blacklisted individuals are kept for the time of the sanction.

Communications tools for the FSFE community

Service

Processing

What data is processed?

Why is the data processed?

What legal authorization do we have according to Article 6 of GDPR?

Who has access?

What is our Data retention policy?

Email server

Emails processing and forwarding

Email addresses + logs (send, receive emails, hostnames, IP addresses of messages sent through SMTP, etc)

To manage the forward email service and assure a basic level of spam control

Consent for providing emails and legitimate interest for spam control

Albert Jonas Matthias Max Paul fellowship@klaproth

1 month

IRC Cloaks

Jabber / XMPP

Massage processing

Account rosters, logs (connect, disconnect, messages process and possibly stored temporally on the server (offline storage + muc preview), status messages, with debug logging up to who talks to whom)

Debugging purposes

Consent for accessing the service

system administrators

2 weeks

Blogs

Writing your blog

Your account (Username, nickname, email addresses, more is optional), your articles, log data

To provide a platform for blogs

Contract

article publicity depends on the owner choosing
sysadmin

Until you delete your blog or we discontinue the service

Employee information and tools

Service

Processing

What data is processed?

Why is the data processed?

What legal authorization do we have according to Article 6 of GDPR?

Who has access?

What is our Data retention policy?

Finance Archive

Storage of financial and employee records

Transaction data from all bank accounts, includes names of all people who send or receive money to/from FSFE.

To do our accounting

Legal requirements (we have to keep them for 10 years by law)

Financial team, tax consultant, legal authorities.

Information older than X>10 (11?) years are deleted after the annual closure of our accounts (to be confirmed 2)

Finance Archive

(not an independent processing)

SSH connections are logged (IP Addresses + username)

for debugging and security purposes

not applicable (not an independent processing)

coordinator and deputy coordinator system administration team , finance team

1 month

FSFE website

Per diem calculator (used for travels reimbursement)

The data entered in the form

To help staffers to calculate allowance

Contract (employment/Intern contract)

Website administrators can access log (to be confirmed 1)

The data is not stored

Weekly timelogs

Communication weekly activities in encrypted mail

Data about time spent on different activities

To keep track of overtime and remaining vacation days

Contract (employment/Intern contract)

Mails encrypted to FSFE Council members

Data should be deleted after accounting for the year is done.

Nextcloud

Nextcloud Account management

Emails and usernames of registered users and the files they work with; calendar and contact entries; webserver logs (user agent)

Main working tool for everyday tasks (from sharing documents to calendar and conatact management)

Contract (employment/Intern contract)

Service maintainers, system administrators

account: (missing information 3) Data: unlimited / until user deletes data; logs of data: until service update

Nextcloud

(not an independent processing)

webserver logs (user agent)

Security and debugging

not applicable (not an independent processing)

Service maintainers, system administrators

logs: until service update

OTRS

Job and internship applications

Job and internship applications are stored as OTRS tickets, after a decision the ticket with attachments will be deleted

Answering and reviewing applications

Consent

FSFE council members and staff. We may share the application with advisors and members

(missing information 4).

Security principles

By default, we apply the following principles to assure the security of your data:

TechDocs/DataProcessingTransparency (last edited 2018-06-05 12:29:23 by mk)